Why Did the President Rely upon a Consultant’s Report for His Decision on the Paris Accord

As noted in the NYT, the President cited this NERA study, commissioned by the American Council for Capital Formation, and the U.S. Chamber of Commerce. Why didn’t the President rely upon his own experts within the White House?

Because:

(screen shot 8:28PM Central 6/2/2017)

While it’s true the Administration has formally nominated Kevin Hassett to CEA chair, it was painfully late that his name was broached.

Of course, there is a separate question whether the President would have listened to Dr. Hassett, even if he had been in place, given what the President has done with information he’s been given by the intelligence services.

37 thoughts on “Why Did the President Rely upon a Consultant’s Report for His Decision on the Paris Accord

  1. CoRev

    Let’s talk reality here. The US Paris Accord commitment is voluntary based upon Obama administration views/requirements/analysis. It is from that voluntary commitment that the Trump administration is withdrawing. Included was a voluntary payment to the “Accord’s” Green Fund from which he withdrew further payments. The “Accord” is still in place with US involvement, but with a different US voluntary commitment. Cost was the basis for his decision. There are few “Cost” studies but several “Cost/Benefit” studies. All are models-based studies. He chose the NERA study.

    Complaining about the Trump’s use of the NERA study is more appropriate if it is compared to other similar studies. But, there are precious few costs studies, so comparing NERA to cost/benefit gets into apples to oranges comparisons. Then we compound the unlike comparisons with benefits being mostly from even more models-based studies. As the NY Times points out how far do we want to rely on: “…relied on dubious data or distorted research reports.”

    Since the US commitment were voluntary for the “Accord”, they were being made mandatory by Obama administration regulation within the US, Trump was actually changing the mandatory Obama implementations. These, mandatory implementations are also from: “…relied on dubious data or distorted research ( models-based) reports.”

    We have two camps. One camp believes in the validity of the models’ outputs, and the other not so much. Trump resides some where in the latter camp, and chose a study that supports his view placing economic growth over models-based potential (benefits and impacts).

    1. 2slugbaits

      CoRev There are a number of methodological problems with the NERA study, which are well documented across various econ blogs. For example, all of the costs are focused on one particular sector of the economy assuming a near zero elasticity of substitution. Relax that assumption and the NERA study pretty much collapses.

      There is a sense in which withdrawing from the Paris Accords would help economic growth, although it involves a rather bizarre notion of economic growth. Ignoring global warming will stimulate a lot of investment as we relocate most urban areas along the east coast, west cost and Gulf cost. But increased investment as a result of deliberate capital destruction is a weird kind of economic growth. At some point economists need to start thinking about NDP rather than GDP.

      1. CoRev

        2slugs, as an OA you know that all studies are flawed. Some more than others. Trump chose a flawed of his choice. Choose your own.

        In another comment you referenced Trump’s “logic”, in this comment your own logic is problematic, ” Ignoring global warming will stimulate a lot of investment as we relocate most urban areas along the east coast, west cost and Gulf cost. ”

        Your knowledge of sea level rise is horrid. The West coast is actually rising and sea level is much less than the East coast where it is sinking. Regardless of plate tectonics, at the current rate of sea level rise, and that rate has been nearly constant for centuries, it would take ~130 to ~200 years for the changes to reach 1 foot at your chosen locations.

        Since you also believe in “…a near zero elasticity of substitution…” was used in NERA, I can only assume you also believe in a near zero elasticity of technology to make absurd predictions of impacts of sea level rise.

        BTW, have you retired yet? If so use your time to learn about a subject instead of relying upon hyperbolic/exaggerated impact predictions. If you have not yet retired, my condolences, but my advice stands.

        1. 2slugbaits

          CoRev A little geometry lesson. The earth is a sphere. If sea level is rising at a constant rate, then the volume of water is increasing at an increasing rate. In any event, NOAA says that the sea level rise is not constant, but is increasing at an increasing rate. But then again, I’m sure your knowledge of sea level behavior is far superior to NOAA’s.

          http://oceanservice.noaa.gov/facts/sealevel.html

          As to the west coast, you seem to think that California constitutes the whole of the west coast. It doesn’t. According to NOAA the west cost from Washington state up through Alaska will be affected.

          https://sos.noaa.gov/Datasets/dataset.php?id=183

          I can only assume you also believe in a near zero elasticity of technology

          Technology won’t advance unless there is R&D and a profit opportunity. If you believe that global warming is a hoax, then there is no rationale for spending R&D money and no business will invest in technology to combat it. You seem to want to have your cake and eat it too. The only way you get technological solutions is if there is an economic incentive to create those solutions. So you really can’t count on R&D and technology solving a problem that you simultaneously claim isn’t a problem. Your position is completely incoherent.

          1. CoRev

            2slugs, please read and understand your own references. For instance: ” The sea level has been steadily rising since 1900 at a rate of 1 to 2.5 millimeters per year. In fact, since 1992 new methods of satellite altimetry using the TOPEX/Poseidon satellite indicate a rate of rise of 3 millimeters per year.” If its not clear these are annual averages, which BTW are contested in several papers which use actual gauge physical measurements.

            At any rate this appears to be my comment for which you provided the geography lesson: “Regardless of plate tectonics, at the current rate of sea level rise, and that rate has been nearly constant for centuries, it would take ~130 to ~200 years for the changes to reach 1 foot at your chosen locations.” Do you actually dispute the time period needed to reach a 1 foot rise? Can you do the math for the NOAA exaggerated rate of 3MM/Yr?

            I often complain about how exaggerated are the estimates used by AGW alarmists. For instance in your NOAA reference it is stated: ” The sea level has been steadily rising since 1900 at a rate of 1 to 2.5 millimeters per year. In fact, since 1992 new methods of satellite altimetry using the TOPEX/Poseidon satellite indicate a rate of rise of 3 millimeters per year.” And yet they used the alarming 3MM.

            Furthermore, your lesson in geography is as funny as so many of your other claims. You said: “As to the west coast, you seem to think that California constitutes the whole of the west coast.” I have no idea how you got to California from a general comment re: the West Coast. But you follow-on was the icing on the “funny” cake. ” It doesn’t. According to NOAA the west cost from Washington state up through Alaska will be affected.” Please note the direction of the arrows from your own reference: https://tidesandcurrents.noaa.gov/sltrends/sltrends.html Was that your interpretation of affected?

            Finally you said: “Your position is completely incoherent.” Really!? After your gross misunderstanding of the data in your own references, it is apparent who is incoherent.

    1. IS

      Bearing in mind that it was seen by many (including me) as not being everything that the world would ever do forever, but a starting point from which we would continue to expand, I think that this response is besides the point. If this withdrawal makes subsequent actions less likely to occur, or likely to be smaller, that must be considered as well.

      And, of course, there’s the more general theme of the US not standing by commitments it has made; this makes the country a less credible negotiating partner not only for climate actions, but military, trade, and others; in this way, it is of a piece with the failure to reaffirm the nation’s commitment to Article 5 of the NATO treaty, pulling out of the TPP, talk of trashing NAFTA, just plain not understanding the way trade agreements between the US and Germany/the EU work…

    2. 2slugbaits

      Perhaps Dr. Roy Spencer has been eating too many steaks at those overpriced restaurants he likes to visit. Anyway, that’s not what the MIT study said:

      http://news.mit.edu/2017/mit-issues-statement-research-paris-agreement-0602

      … the 0.2 degree-figure used in the talking point reflects the incremental impact of the Paris Agreement compared with the earlier Copenhagen agreement. If you instead compare the impact of the Paris Agreement to no climate policy, then the temperature reduction is much larger, on the order of 1 degree Celsius — 1.8 degrees Fahrenheit — by 2100. This would be a significant reduction in the global temperature rise, though much more is needed if the world is to achieve its goal of limiting warming to 2 degrees Celsius or less.

      1. Corev

        2slugs, it’s this kind of exaggeration: ” If you instead compare the impact of the Paris Agreement to no climate policy,…” Why compare to something that is not happening, no climate policy? The incremental .2C is based upon existing policy. The .2C was also confirmed by Longberg in another 2015 study.

        What few are considering is that the .2C overall reduction is if the Paris Accord is fully implemented. The US portion is a fraction of that (~.04C), and to see that difference the US would have to change totally from its current policies. No one is proposing that.

        1. 2slugbaits

          CoRev Dropping the Paris Accord in-and-of-itself probably doesn’t represent all that much of a problem. But it begs some obvious questions. If Trump wants to withdraw from the Paris Accord, does he still intend to follow through with the goals of the Copenhagen Accord? The rationale he gave for dropping out of the Paris Accord would logically seem to apply to the Copenhagen Accord as well, since both are voluntary and both are seen by his supporters as economic burdens falling unfairly on the US. Granted, Trump is a scatterbrain, so inconsistency probably isn’t a big deal to him (or his supporters), but some of us appreciate logical consistency.

          It also begs the question why the supposed relative smallness of the temperature reduction even matters. Is Trump saying that he doesn’t support the Paris Accord because it is only a 0.2 degree improvement over the Copenhagen Accord, but he would have been fine with it if the Paris Accord was a 2.0 degree improvement??? If Trump’s real concern was that the Paris Accord didn’t go far enough in reducing temperatures, then why didn’t he recommend “pump priming” the Kyoto agreement? Hey, he likes “pump priming”….he invented the phrase. Again, saying something like that would contradict years of everything he has said in the past.

          1. CoRev

            2slugs, Kyoto ended in 2012. Plus we have historical records of its impact.

            Ask Trump for answers to your questions. If logic is your concern why try to re-implement Kyoto?

  2. pgl

    A study commissioned by the American Council for Capital Formation, and the U.S. Chamber of Commerce.

    That basically says it all.

  3. pgl

    NERA is forecasting a 9% reduction in GDP by 2040 as well as 31.6 million lost jobs. This strikes me as an absurd analysis comparable to what one would have gotten from the Heritage Foundation.

    1. Steven Kopits

      The NERA study estimates the impact on GDP of an 80% reduction in carbon emissions by 2050. At a decline of relative decline of 9% of GDP, I think the impact is grossly understated. An 80% CO2 reduction would imply essentially weaning the US from the fossil fuels upon which our civilization is currently based. My recent analysis suggests that we are reaching the limits of fuel efficiency gains, and thus such great reductions in fuel use would largely imply real reductions in activity.

      I would note, however, that employment and GDP are not necessarily related. Rather, workers will be moved from higher productivity to lower productivity jobs. Real incomes will be affected, but employment levels as such are not linked to GDP levels at all.

      Given an aging population, extravagant pensions, welfare and healthcare promises, I personally doubt that the NDC (Paris) targets are consistent with maintaining the US as a functioning democracy, or indeed, society as we know it.

      *********
      From the NERA study:

      “[T]he Obama Administration participated in meetings in Paris at the end of 2015 that created a new framework to reduce GHG emissions, based on voluntary “Nationally Determined Contributions” (NDC) from each country. The U.S. pledged in its initial NDC to reduce emissions more rapidly and further than the CPP alone would do, and in its 2016 Second Biennial Report of the United States of America1
      (USSBR 2016) submitted to the United Nations (UN), it described in broad terms what additional regulations would be required to achieve those goals. The USSBR 2016 provides some options to achieve the 2025 NDC target to reduce net GHG emissions by 26 to 28% relative to 2005 levels. The U.S. NDC from the Paris Agreement is consistent with a straightline emissions reduction pathway to economy-wide emission reductions of 80% or more by 2050.

      “[W]e develop a slate of scenarios to bracket the potential economic impacts on the industrial sectors and the economy as a whole from the U.S. reducing its GHG emissions as specified in its NDC. The scenarios employ a combination of market based and direct measures to restrict GHG emissions. The core scenarios are constructed so that the U.S. as a whole ultimately meets its NDC emission target.”

      1. lxm

        “I personally doubt that the NDC (Paris) targets are consistent with maintaining the US as a functioning democracy, or indeed, society as we know it.”

        Evidently that’s what the Mayans thought as well. So they continued to cut down the forests. It was how they knew to prosper.

        The Mayan civilization was sophisticated enough to know that they couldn’t continue down the same road forever. But they did anyway. From the Smithsonian:

        “The collapse is especially intriguing because it seemingly occurred at “a time in which developed a sophisticated understanding of their environment, built and sustained intensive production and water systems and withstood at least two long-term episodes of aridity,” says B.L. Turner, the lead author of the ASU study. In other words, the Maya were no fools. They knew their environment and how to survive within it—and still they continued deforesting at a rapid pace, until the local environment was unable to sustain their society.

        Read more: http://www.smithsonianmag.com/science-nature/why-did-the-mayan-civilization-collapse-a-new-study-points-to-deforestation-and-climate-change-30863026/#1btwhv6uIUayKiTq.99

        You, sir, strike me as but another Mayan unable to change gears in a changing world.

  4. randomworker

    It’s purely signaling. He didn’t need a “study” because this was an easy campaign promise to check off. Was he ever not going to do this? Impossible.

    I think not being a part of the Paris Accord has other consequences. Abdicating leadership, not being at the table, not being in the room when decisions are made, etc. Plus who knows, Macron might be a good friend to have. He seems to be hitting the ground running, as opposed to our doddering pussygrabber.

    80k white guys in MI, WI, and PA got butthurt and voila, Trump. This is what they wanted. The louder the crying from the other side, the more they like it. So imo, invest in Europe and Asia. Fight other battles. Let Paris go.

  5. PeakTrader

    Kyoto Protocol:

    “The Only Nations That Haven’t Signed the 1997 Global Climate Treaty are Afghanistan, Sudan & the U.S.A. A total of 192 countries have signed and ratified the Kyoto Protocol, the 1997 treaty that’s the closest thing we have to a working global agreement to fight climate change.”

    Sound familiar?

    Why Bush rejected Kyoto Protocol:

    “As you know, I oppose the Kyoto Protocol because it exempts 80 percent of the world, including major population centers such as China and India, from compliance, and would cause serious harm to the U.S. economy. The Senate’s vote, 95-0, shows that there is a clear consensus that the Kyoto Protocol is an unfair and ineffective means of addressing global climate change concerns.”

  6. CoRev

    The Kyoto Climate Protocol – December 11, 1997
    Copenhagen Accord – 18 December 2009
    Paris Climate Agreement – 12 December 2015

    If you are a believer in AGW how they effected Global Average Temperatures – http://www.woodfortrees.org/plot/wti/from:1997.9
    If you are a believer in AGW how they effected CO2 – http://www.woodfortrees.org/plot/esrl-co2/from:1997.9

    If you are a believer in AGW you believe in Anthropogenic CO2 being the driver of Global Temperature change. These three major international climate agreements have had almost no effect on the increase in atmospheric CO2. Meanwhile since Kyoto the Global Average Temperatures have been nearly stable with the exceptions of el Ninos/la Ninas. No science has linked Nino/as to anthropogenic causes.

    So just what are the vocal minority of AGW believers protesting? What is your evidence based upon, other than more model-based estimates produced by other believers in AGW scientists?

    I’ll await your reality-based evidence.

    1. 2slugbaits

      CoRev If you actually understood time series analysis you would know why your claim is false. You would also test the residuals coming out of that tool. Hint: I tested them and they flunk all of the basic tests. Of course, you would probably need real time series software and not that joke of a tool you keep linking to. But aside from that, I’m not quite sure what your point is. If you’re saying that the previous agreements haven’t made any difference in CO2 emissions, isn’t that an argument for stronger and more binding agreements?

      1. Corev

        2slugs, just which claim do you reject?

        ” I’m not quite sure what your point is. If you’re saying that the previous agreements haven’t made any difference in CO2 emissions,…} Do you dispute that CO2 has continued to rise during the various attempts to mi5igate?

        “…isn’t that an argument for stronger and more binding agreements?” Re-read Trumps announcement re: the Paris Accord. At what cost do you want to pay for indiscernible change?

        Can you support any of your contentions?

      2. baffling

        2slugs,
        i wouldn’t waste my time trying to convince folks like corev and others of similar ilk about global warming. they have been presented data time and time again, but choose to ignore what is actually occurring. decades ago, two sides were formed. as the data became more clear on what is happening to the globe, one side’s position was strengthened and the others severely weakened. but the deniers cannot admit they were wrong, so they simply continue to entrench. there really is no amount of data that exists which could get folks like corev, peak or rick to reconsider their position. they are captains wiling to go down with their ship.

  7. PeakTrader

    The shale revolution, without government help, allowed natural gas to replace coal (natural gas emits over 50% less CO2 than coal).

    Without the shale revolution, it would’ve been very expensive – even more expensive – to reduce CO2 emissions.

    Eventually, there will be a revolution in renewable energy, including batteries. Perhaps, some government subsidies will help, including for clean coal technology, since the U.S. has abundant coal reserves.

    1. PeakTrader

      There’s a long history of oil & gas firms and government involvement in fracking. However, it didn’t pan out.

      Shale Gas – Wikipedia

      “Shale gas was first extracted as a resource in Fredonia, New York, in 1821, in shallow, low-pressure fractures. Horizontal drilling began in the 1930s, and in 1947 a well was first fracked in the U.S..”

      One man pioneered the economic extraction of shale gas.

      George P. Mitchell

      “The rise [in shale gas] has been helped along by a variety of factors…. But the biggest difference was down to the efforts of one man: George Mitchell, …who saw the potential for improving a known technology, fracking, to get at the gas. Big oil and gas companies were interested in shale gas but could not make the breakthrough in fracking to get the gas to flow. Mr Mitchell spent ten years and $6m to crack the problem (surely the best-spent development money in the history of gas). Everyone, he said, told him he was just wasting his time and money. ” — The Economist, July 2012

    2. spencer

      Yes, Mitchell was a pioneer in the initial scientific studies of fracking.

      But it was really proven commercially viable in a joint program between Mitchell Energy and the Department of Energy. It was a joint venture largely because Mitchell Energy found that running the first large scale fracking program was so expensive that they could not afford to take the risk. If it had failed they would have been bankrupt. So they undertook a joint program with the Department of Energy where the government took on much of the financial risk and both parties provided extensive technical expertise.

      It was a fine example of how much of the post-WWII scientific applications of new technology was fueled
      by joint public-private efforts.

      This article from Forbes — not a liberal organization –provides a much more balanced history than the Wikipedia article.

      https://www.forbes.com/sites/lorensteffy/2013/10/31/how-much-did-the-feds-really-help-with-fracking/#530c15873edf

        1. spencer

          As are almost any article you can find.

          SO WHAT ????

          iT DOES NOT CHANGE THE FACTS i POINTED OUT THAT MAKING FRACKING COMMERCIALLY VIABLE WAS A JOINT PUBLIC-PRIVATE PROJECT.

          1. PeakTrader

            It wasn’t a public-private project. It was George P. Mitchell, “the father of fracking,” who made it commercially viable – not other oil & gas firms and the government.

            You give too much credit to government and not enough to individuals, like Edison, Tesla, Ford, Vanderbilt, Carnegie, etc..

    3. baffling

      peak, it is probably fair to say the recent growth of nat gas (and fracking) is a fairly direct result of the mandated reductions in coal, enforced by policy. “The shale revolution, without government help,” statement is probably not accurate. Businesses began looking at shale more seriously as coal became less of an option. government policy helps.

      but shale fracking is only a temporary solution-and not environmentally friendly. I have uncles who sold shale rights on their properties, and are not really pleased with the local impacts on water, etc. they are staunch republicans, but “surprisingly” have taken quite liberal positions in response to the local fracking and environmental issues. well water has been impacted. renewables are really the way forward. look at texas. they are now a huge wind farm, courtesy of state support of renewables. yes, rick perry was a socialist when it came to renewable energy support in the state of texas.

  8. Anonymous

    US oil production is increasing again. And that with prices at $50 rather than $100.

    http://www.reuters.com/article/us-usa-shale-column-idUSKBN18S5O

    U.S. shale booms and depresses oil prices again: Kemp

    By John Kemp | LONDON

    “U.S. oil production continues to rise relentlessly, frustrating efforts by OPEC and non-OPEC oil exporters to rebalance the global market and secure an increase in the price of crude.

    After a devastating slump in 2015 and 2016, the U.S. oil industry has returned to strong growth, with drilling and output rising rapidly (tmsnrt.rs/2qJXDCG).

    U.S. production is now forecast to grow by an average of 440,000 barrels per day (bpd) in 2017 and another 650,000 bpd in 2018, according to the U.S. Energy Information Administration (EIA).

    U.S. crude and condensates output rose by 62,000 bpd month-on-month to almost 9.1 million bpd in March (“Petroleum Supply Monthly”, EIA, May 2017).

    Production has increased by more than 530,000 bpd from its recent low of less than 8.6 million bpd in September, adding to an already well-supplied global market and delaying a drawdown in stocks.

    Weekly estimates prepared by the agency indicate output continued to increase in April and May and now stands at around 9.3 million bpd (“Weekly Petroleum Status Report”, EIA, May 19).

    While the weekly estimates are considered less reliable than the more comprehensive monthly numbers, they have generally provided a good guide to trends in the monthly data (tmsnrt.rs/2reYzCF).

    Most of the extra output between September and March came from oilfields in the Gulf of Mexico, where production increased by 257,000 bpd, and Alaska, where output was up by 74,000 bpd.

    But production from fields in the Lower 48 states excluding the Gulf of Mexico, most of which comes from onshore shale plays, also rose, by 200,000 bpd (tmsnrt.rs/2qJOnyN).

    In March alone, production in the Lower 48 states excluding the Gulf of Mexico rose by 35,000 bpd to its highest level in nearly a year (tmsnrt.rs/2qJT5fH).

    U.S. shale output will almost certainly rise substantially in the rest of 2017 and into 2018 given the typical six-month lag between spudding new wells and the beginning of their commercial production.

    Reported output for March mostly reflects wells started before the end of September 2016, when there were fewer than 425 rigs drilling for oil in the United States, according to oilfield services company Baker Hughes.

    The number of active oil rigs has now increased to 722, and thousands of extra wells have been drilled in the meantime, with many still waiting on completion services before starting to flow.

    As these wells are hydraulically fractured and connected to gathering systems, production will increase further in the remaining months of 2017 and into early 2018.

    The speed and scale of the surge in U.S. production has surprised most within the oil industry, even top forecasters…”

  9. CoRev

    Menzie, why did you write this article? In particular why did you concentrate on Hassett: “Why didn’t the President rely upon his own experts within the White House?…While it’s true the Administration has formally nominated Kevin Hassett to CEA chair, it was painfully late that his name was broached.

    Of course, there is a separate question whether the President would have listened to Dr. Hassett,”

    Do you have knowledge that any of the White House experts have participated in an appropriate study of the Paris Accord? What makes any of them, including Hassett, an expert on Paris Accord costs? Are you so sure that Trump did not listen to Hassett? AEI did very recently write on the Paris Accord: https://www.aei.org/publication/the-absurdity-that-is-the-paris-climate-agreement/ but did not cover detailed costs. Their comment: “This effort to reduce GHG emissions would impose costs of at least 1 percent of global GDP, or roughly $600 billion to $750 billion or more per year, inflicted disproportionately upon the world’s poor. ” Are you so sure he did not refer to an listen to his experts? Much reporting says otherwise including outside experts.

    1. Menzie Chinn Post author

      CoRev: If you knew anything about the CEA, you wouldn’t write what you wrote. CEA is the in-house economic think tank for the Executive Office of the President. It has experts on a wide range of topics, and those experts are tasked to assess the validity of studies.

      See for instance here.

      1. CoRev

        Menzie, I asked you a series of simple questions testing your sources for the article. You failed to answer any of them. Do you have any source(s) indicating Pres. Trump did NOT refer to his White-House experts? Are you so sure he did not refer to and listen to his experts, including those in the CEA?

        Wow, you had to go back to the 2008 Right Whale article.

        1. Menzie Chinn Post author

          CoRev: Not once in any commentary on the Paris Accord has the President noted an Administration document. I’ll take that as suggestive. Typically, the President does refer to Administration analysis if he has consulted with them. But I cannot prove he did not, much like I cannot prove that you have stopped beating your spouse.

          1. Corev

            Menzie, you’ll have to talk to Ms CoRev for confirmation. Since you’re suggesting the existence of an Administration document, do you know of one. I have only seen two such docs to date. Neither are from any Govt entity. I’m not sure there was a cost estimate developed for the Accord proceedings. There may be one, since AEI used some Gross estimates of cost.

          2. Menzie Chinn Post author

            CoRev: As a former CEA staffer (2000-01, under Clinton and G.W. Bush), I would say if the President asks for information/advice, a memo is written. I do not suggest a document was written. I am suggesting that he did not ask advice from CEA, and hence no document was written.

          3. CoRev

            So, your complaining was just supposition, and your complaint was that CEA may not have been consulted on future costs. There already was an economic history from the Obama implementations.

            I did quite a few cost/benefit studies in my past career, and have learned that there is an area of diminishing returns when your study’s baseline cost conditions/assumptions far exceed any baseline benefits conditions/assumptions. In fact we were able to recommend the cessation of several types such studies in regulations.

            I am sure that those conditions exist in this instance. The temperature impacts have been known, even before the Accords signing http://onlinelibrary.wiley.com/doi/10.1111/1758-5899.12295/full, and the costs I believe costs and economic impacts were part of the Accord deliberations. There were, after all, more than a few noted economists among the Accord’s negotiators. I also suspect that if we looked at the list of attendees/negotiators we would find current members of the US CEA represented.

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